Finding Text
2022-011 ? Institutional Higher Education Emergency Relief Funds III Student Outreach Requirement Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Earmarking). Program. COVID-19 - Higher Education Emergency Relief Fund; Assistance Listing Number 84.425F. Criteria. The University is required to use a portion of Higher Education Emergency Relief Funds III (HEERF) institutional funds to (a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and (b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University must also document how the amount of the HEERF grant spent on these two required activites was reasonable and necessary given the unique needs and circumstances of the University. Condition. The University did not use a portion of the institutional HEERF III grant to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the HEA. The University also did not document how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique circumstances of the University. Cause. This condition appears to have been caused by management lacking the appropriate knowledge and understanding of the grant requirements. Additionally, there was not appropriate oversight of accounting personnel involved in the grant management to ensure grant requirements were being satisfied. Effect. As a result of this condition, the University did not fully comply with the requirements of the HEERF III grant. Questioned Costs. No costs have been questioned as a result of this finding inasmuch no unallowable costs have been identified. Recommendation. We recommend that management review the compliance requirements of each grant when received to ensure compliance with such requirements. View of Responsible Officials. Management agrees with the finding. See corrective action plan.